Libratum Therapy understands that your privacy is important to you and that you care about how your personal data is used. Our aim is to respect your privacy and comply with the General Data Protection Regulation (GDPR). The following summary highlights how we use, collect and hold your personal data and how we are currently implementing General Data Protection Regulation or GDPR. Please see https://ico.org.uk for more details.

 The Data Controller

Libratum Therapy Ltd is the Data Controller for any personal data you give to us. Libratum Therapy Ltd is registered with the Information Commissioner's Office. Libratum Therapy® Ltd, a company registered in England with company number 13912591.

 We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 Our full details are:

Address: Harrison House, Sheep Walk, Langford Road, Biggleswade, Bedfordshire, SG189RB. 

Email:enquiries@libratum.co.uk
Website:www.libratum.co.uk

 It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

Why do we keep information?

Our professional registration requires us to keep personal data or information about our clients and the work that we do. Personal data refers to any information about you that enables you to be identified. We cannot offer you services unless you allow us to keep data about you and our work together, and we have a legitimate interest for keeping your data. We are registered with the Information Commissioners Office (ICO) to do so. We are bound by the ethical and practical rules set by our professional regulatory bodies (the Health and Care Professions Council; HCPC, and the British Association for Behavioural and Cognitive Psychotherapies; BABCP).

What kind of information do we keep?

Keeping records is an essential component of healthcare. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Sensitive Data includes information about your race or ethnicity and health, including information about your existing and previous medical conditions, medication details, psychiatric history and any other relevant health information to enable us to carry out our services to you.

We require your explicit consent for processing sensitive data, so when you submit your details, we will ask you to confirm your consent to this processing. 

We do not collect any other Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or goods). In this case, we may have to cancel a service or product you have with us but we will notify you if this is the case at the time.  

Prior to our first appointment, you will be asked to complete an information sheet and email consent form.

How is your personal data collected?

We use different methods to collect data from and about you including through: 

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms before or during an appointment, verbally during discussions at our practice, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our services;

  • attend one of our therapy sessions;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing or any other information to be sent to you; or

  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. 

• Third parties or publicly available sources. We will receive personal data about you from various third parties (such as health providers) and public sources as set out below:  

(i) Technical Data from the following parties: 

(a)   analytics providers such as [Google] based outside the EU; and 

(b)  advertising networks such as Facebook, Instagram and Twitter based outside the EU.

(ii) Identity and Contact Data from third party healthcare professionals where you have been referred to us from another healthcare clinician.

(iii)  Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

What do we do with the information and what is the purpose for which we will use your personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.

• Communicating with you. This may include responding to emails or calls from you.

• For billing and processing payments.

• To help prevent serious harm.

• Where we need to comply with a legal obligation.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing  

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).  

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.  

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Who might we share personal information with?

We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your personal information with any third parties. However, in some limited circumstances, we may be legally required to share certain personal data with a third party and/or legal authorities, such as:

·      If you are referred by your health insurance provider, or otherwise claiming through a health insurance policy to fund therapy, then we will share appointment schedules with that organisation for the purposes of billing. We may also share information with that organisation to provide treatment updates.

·      If there is need-to-know information for another health provider, such as your GP.

·      If the information concerns risk of harm to the client, or risk of harm to another adult or a child. We will discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else.

·      If disclosure is in the public interest, to prevent a miscarriage of justice

·      If there is a legal duty, for example if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority

·      Service providers, acting as processors who provide IT and system administration services. 

·      Professional advisers and associates, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, associates, auditors and insurers who provide consultancy, banking, legal, insurance, support and accounting services. 

·      HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances. 

·      Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 International transfers 

We may transfer your data outside the European Economic Area (EEA). Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:  

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.  

How will we store records?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

• All information recorded on paper will be securely stored in a locked filing cabinet

• Confidential digital information will be stored on a password protected laptop computer

• All electronic devices (e.g. computer, laptop and phone) used to access stored information will themselves be password protected

• Letters sent to professionals such as GP’s will be encrypted and password protected, with the password sent separately

 How long do we keep records for?

• We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or police investigation in respect to our relationship with you. 

• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

• By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. 

• Mental health records are subject to special legislation e.g. adult records are kept for 8 years after the last contact with the service www.gov.uk/government/publications/records-management-code-of-practice-for-health-and-social-care. This benchmark will be applied to all clinical records made in the process of engagement with our therapy.

• Some records may be held indefinitely if there were any issues of concern that could lead to police investigation in the future. 

What are your rights?

• The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.

• The right to access the personal data we hold about you (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.

• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

• The right to restrict (i.e. prevent) the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:  

o   If you want us to establish the data's accuracy. 

o   Where our use of the data is unlawful but you do not want us to erase it. 

o   Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.  

o   You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  

·      The right to object to us using your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

 If you wish to exercise any of the rights set out above, please contact us.  

We aspire to the highest data privacy standards. If you have questions, concerns or feedback then please let us know so that we can address them. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) and you can visit www.ico.org.uk/concerns or phone 0303 123 1113.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email of Libratum Therapy.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

We will try to respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex or you have made a number of requests, more time may be required . You will be kept fully informed of our progress.

E-mail Correspondence

Libratum Therapy would like clients to have the opportunity to communicate by e-mail and e-mails will be accessed by the Libratum Therapy® practice.

Please be aware that that communication via e-mail has a number of risks, which include, but are not limited to, the following:

• E-mail can be circulated, forwarded and stored in paper and electronic files.

• Backup copies of e-mail may exist even after the sender or the recipient has deleted his/her copy.

• E-mail can be received by unintended recipients.

• E-mail can be intercepted, altered, forwarded or used without authorization or detection.

• E-mail can be used to introduce viruses into computer systems.

Guidelines for e-mail communication:

• Please inform Libratum Therapy of changes in your email address.

• Please include your name and phone number in the email.

• The e-mail message is not time sensitive. We cannot guarantee that any e-mail will be responded to within any particular time.

• The content of the email should only be used for non-sensitive and non-urgent issues.

• Email should not be used if you are in crisis.  In case of emergency please contact the crisis lines as detailed above.

Website

Our website may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by us. We use Cookies to facilitate and improve your experience of our website and to provide and improve our products and/or services. In addition, our website uses cookies so that we can see how many people have visited our site, how people use our site and which pages are most popular. Google may send additional cookies if you use the Google map links on the site. Cookies are anonymous and contain no personal data. You can turn cookies off in your website browser if you wish to.  For more information about the cookies we use, please see our Cookie Policy.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

E-mail: enquiries@libratum.co.uk

Telephone: (+0044) 020 7164 6934

Changes to this Privacy Notice

We keep our privacy policy under regular review. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection. Information relating to any changes will be made available on our web site (www.libratum.co.uk). This version was last updated in April 2022.